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FTC’s Click-to-Cancel Rule Vacated Ahead of Planned July 14 Effective Date

On July 8, 2025, a three-judge panel of the US Court of Appeals for the Eighth Circuit issued a per curiam opinion vacating the US Federal Trade Commission’s (FTC’s) Negative Option Rule (Click-to-Cancel) on Administrative...more

Ensuring Compliance with ‘Junk Fee’ Regulatory Requirements

With the continued expansion of the regulation of “junk fees,” including bipartisan actions from federal, state, and local authorities, it is more important than ever for businesses to ensure compliance with these...more

FTC Issues Final ‘Junk Fees Rule’ to Crackdown on Aggressive Pricing Practices

The Federal Trade Commission (FTC or Commission) recently issued a final rule (the Junk Fees Rule or the Rule) banning so-called “junk fees” in two key industries: short-term lodging and live events. The Rule addresses...more

Recent Crackdown on Junk Fees: Federal, State, and Private Actions

What Are Junk Fees? “Junk fees” refer to the broad swath of fees and charges, often mandatory, that are not included in the initial offered price of a good or service. Common examples include mandatory fees charged by hotels,...more

FTC’s Final ‘Cars Rule’ on Dealer Sales Practices: Implications for Banks, Auto Finance, and ‘captives’

The Federal Trade Commission recently issued a final rule that is squarely aimed at changing the way dealers interact with customers in the financing process. The final rule takes effect on July 30, 2024....more

Federal, State Agencies Want to Dump Junk Fees: How to Manage Business Risk

Businesses should be aware that the Biden administration continues its attempt to curb junk fees, with additional actions proposed by the Federal Trade Commission and Consumer Financial Protection Bureau....more

Latest Developments in Automotive Finance and Consumer Protection

Federal agencies such as the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC) have increased their scrutiny of auto loan servicing activities, particularly regarding auto dealers who engage in...more

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